history of animal air transport

History of AnimalAir Transport

Marshall Meyers, LL.B | ATA Conference 2020

Through the years…

When Pigs Fly!

InstoneAir Imperial BOAC BA1920• First airline to transport racehorse

• Grouse from Scotland

1935 First Transatlantic Animal Shipment

• Five Neon tetras

flown on Hindenburg

1969 Publishes IATA Manual for the Carriage of Live Animals by Air

1969 Live Animals Board established

2008 Established the Animal Care Team and the Advisory Panel

International Air Transport Association

1945 Founded

Mission: Represent, lead and serve the air transport industry

1945 National Skyway Freight (NSF)The Flying Tiger Line

“Anything, Anytime, Anywhere”

1947 Returning Racehorses after WWII

1949 Flying Tigers Introduced:

• Refrigeration units designed to transport lobsters Maine-California

• Redesigned a C-47 so entire main deck cargo compartment was refrigerated

Early Horse Transport

Horse Transport

ULD-BC-1

4-Horse Stall

Early Cattle Transport

Cattle Transport

Livestock

Transport

Aquatics

Transport

Wildlife Transport

Wildlife

Transport

Wildlife Transport

Wildlife

Transport

Pet Carriers

What role has regulation played in advancing animal transport?

1961 British Standards for The Carriage of Live Animals by Air

1969 IATA Manual for the Carriage of Live Animals by Air

1969 US Civil Aeronautics Board (CAB) Investigation of Premium Rates

for Live Animals and Birds

1973 CAB -- Investigation of Rules and Practices Relating to Acceptance

and Carriage of Live Animals in Domestic Air Freight Transportation

1975 US Animal Welfare Act Animal Transport Regulations

British Standards

IATA Live Animal

Standards

1970

2020

66 pages

492 pages

1975 CAB -- IATA Live Animal Regulations Investigation

1977 India Animal Transport Standards (Dogs/Cats) published

1977 EU Directive No. 1/200/10 Protection of Animals During Transport

1977 US -- All-Cargo Airline Deregulation Act

1978 US -- Airline Deregulation Act

1981 CITES Guidelines for Transport and Preparation for Shipment of Live Wild

Animals and Plants

Animal Transport Regulations

Indian Standards

1975 CAB -- IATA Live Animal Regulations Investigation

1977 India Animal Transport Standards (Dogs/Cats) published

1977 EU Directive No. 1/200/10 Protection of Animals During Transport

1977 US -- All-Cargo Airline Deregulation Act

1978 US -- Airline Deregulation Act

1981 CITES Guidelines for Transport and Preparation for Shipment of Live Wild

Animals and Plants


1986 US Air Carrier Access Act (Emotional Support/Assistance Animals)

1993 USFWS Regulations governing transport of live wildlife animals

2004 EU Council Regulation No. 1/2005 Protection of Animals During Transport

2013 USFWS Regulations governing transport of CITES –listed Species

2019 EU Council Regulation No. 1/2005 – proposed revisions under review


EU Council Regulations

Pet industry challenged 300% premium rates for Live Animals and Birds

Airlines Justification:

Special handling – time sensitive and dedicated personnel

Hand loaded – one box at a time - not use mechanized loading

Never co-mingled live and inanimate freight,

Special temperature controls

Ventilation access for all shipments

Special terminal holding facilities

Loading Charts based on species physiological traits

1969 – US Civil Aeronautics Board

Investigation of Premium Rates for Live Animals

and Birds

1973 CAB Found Shippers’ Evidence Contained:

• Photographs depicted actual operations

• Copies of airline manuals revealed different processes

• Air freight air bills reflected discriminatory practices in tariff rates and rules

• Douglas 1954 Animal Physiology Study +/- 50% error, invalidated load planning criteria

• Individual airline internal Time and Motion Studies disputed carrier claims

• Airline standards including IATA LAR as archaic, unrealistic and out-of-date

1973 CAB Decision:

• 10% premium for warm-blooded animals

• 0% premium for cold-blooded animal

• Airlines and shippers need to collaborate to develop safe standards for

acceptance and transporting live animals, and launched an “Investigation to

Establish Rules and Practices Relating to the Acceptance and Carriage of

Live Animals” which published standards in 1975

IATA Rejected Shipper Involvement

Mid 1970s: Shippers obtained CAB order enjoining application of LAR

to/from US until IATA provided shippers opportunity to participate in

Live Animal Board deliberations

1978: IATA opened the doors

FAA tie-down rule -1978

Each animal’s container in a cargo compartment

must be:

• Securely attached to the compartment

• Use webbing, partitions to prevent crushing

• Must ensure ventilation for all containers

• All animal containers must be level with

the ground “at all times”

Airlines and animal shippers challenged

tie-down proposal

Live animal shipper parties Petition to Rescind Rule

was granted 45 minutes before effective

IATA Live Animal Regulations (LAR) Today!

• IATA standards in the LAR no longer developed in isolation

• Revisions based on input from diverse group of interested parties —

IATA airline members; shipping industry stakeholders, trade representatives

and others with expertise in animal transport; International Governmental

Organizations (OIE, CITES); LAPB Animal Care Team; LAPB Advisory Panel

• LAPB meets twice a year to review proposals/approve updates

Current Regulatory Initiative


Assistance Animals / Emotional Support Animals


US DOT Evaluating

Assistance/Emotional Support Animals

Department of Transportation seeking comments on amending Air Carrier Access

Act (ACAA) regulations covering service animals to ensure system is safe for

traveling public and accessible to individuals with disabilities.

Propose: Define service animal under DOT ACAA regulations (14 CFR Part 382)

a dog individually trained to perform tasks for qualified individuals

with a disability --- physical, sensory, psychiatric, intellectual, or

other mental disability.


DOT Also Proposes to Allow Airlines

• Recognize emotional support animals as pets not service animals,

• Require passengers with disability execute DOT forms attesting to animal’s

training and good behavior

• Limit number of service animals -- two (2) service animals

• Allow airlines to require service animals fit within its handler’s foot space

DOT Docket Dot-OST-2t018-0068 Public Comments Due: April 6, 2020

Current U.S. Regulatory Dilemma

50 CFR 14.111(e)

USFWS – Is “Last On/First Off” mandatory?

2019 - Airline cited for failure to comply despite aircraft manufacturer’s

recommended loading protocols

Faced excessive fines despite the fact USFWS in 1994:

“Last On/First Off” is guideline not a violation…

An Ongoing Dilemma: Which Version of the IATA LAR Applies?!

• Current EU Regulation 1/2005 Annex 6 mandates 31st Edition (2004)

• Current USFWS 50 CFR § 14.106 20th Edition (1993)

• Current USFWS 50 CFR § 23.29 40th Edition (2013)

Is one required to comply with the current LAR and face prosecution

for not complying with out-of-date LARs that may

compromise animal welfare and safety?

Routes Dashboard

www.routespartnership.org

Focus on Wildlife Trafficking

www.traffic.org/site/assets/files/10858/in_plane_sight.pdf

CEIV Live Animals

• Improve animal welfare and safety

• Enhance standardization

• Enforce Live Animal Regulations (LAR)

• Elevate staff and increase professionalism

• Enable increased stakeholder collaboration

• Promote uniform approaches in multimodal animal transport

• Reinforce trust through transparency and communication

www.iata.org/en/programs/cargo/live-animals/ceiv-animals

“Anything,

Anytime,

Anywhere!”

Interesting Carrier Bans

• Wild caught animals except whales, bats, elephants, fish >50kg

• Bird shipments exceeding 5 birds

• Poisonous/venomous animals except bumble bees

• CITES-listed species

• Zoological animals unless to Government-owned zoos,

• Zoological animals unless between recognized zoos(AZA, WAZA, EAZA)

• Animals used for laboratory, medical or scientific experimentation or research

Interesting Carrier Bans

• Any animals used for exploitation

• Wild animals unless between legitimate scientific institutions

• Shark fins for human consumption

• All animals but live aquatics, crustaceans, worms, snails & mollusks

• No personal birds except Falcons in passenger cabin

• Hunting trophies

• All birds but domestic birds

• ++++++++++++

Are airlines common carriers with a duty to serve and not engage in discriminatory

practices such as:

• refusal to transport a commodity due to its presumed or stated intended use

• refusal to transport due to activist opposition?

Can an airline refuse to accept animal shipments that can:

• be safely and humanely transported

AND • do not interfere with the safe operation of the vehicle (e.g. aircraft)?

Persistent Pending Questions

Docket DOT-OST-2018-0124

Special Thanks

Vic Attwood

Tristan Bradfield

Filip Vande Cappelle

Jennifer Chatfield

Bruce Clemmons

Christopher Dehio

John Dickson

Andrea Gruber

Andreas Kaufman

Frank Kohn

Tim Harris

Jeremy Instone

Gabriella Tamasi

Raymond Tilberg

Guy Van Herbrugen

Robert van Voorthuysen

Kelly Wheeler

Frank Young

and those I forgot!

BA Speedbird Centre

Flying Tigers Club

history of animal air transport

Documents